Conformity Analysis and Determination Report

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1 Conformity Analysis and Determination Report 2035 Long Range Transportation Plans: Burlington-Graham Metropolitan Planning Organization (Guilford County) Greensboro Urban Area Metropolitan Planning Organization (Guilford County) High Point Urban Area Metropolitan Planning Organization (Guilford, Davidson and Forsyth Counties) Winston-Salem Urban Area Metropolitan Planning Organization ( Forsyth, Davidson, and Davie Counties) February 2009 Final Report Adopted Prepared by: The Piedmont Authority for Regional Transportation, In Partnership with the: Burlington-Graham Metropolitan Planning Organization, Greensboro Metropolitan Planning Organization, High Point Metropolitan Planning Organization, Winston-Salem Metropolitan Planning Organization, and In cooperation with The North Carolina Department of Environment and Natural Resources Division of Air Quality and The North Carolina Department of Transportation - Transportation Planning Branch

2 Contact Information Additional copies of this report can be obtained from the: Piedmont Authority for Regional Transportation 7800 Airport Center Dr., Suite 102 Greensboro, NC or North Carolina Department of Transportation Transportation Planning Branch 1554 Mail Service Center Raleigh, NC

3 TABLE OF CONTENTS CONFORMITY ANALYSIS AND DETERMINATION REPORT OVERVIEW... 1 EXECUTIVE SUMMARY INTRODUCTION AIR QUALITY PLANNING Emissions Budget and Baseline Emissions LONG RANGE TRANSPORTATION PLANS Consultation Financial Constraint Assumptions Latest Planning Assumptions Future Year Roadway Projects Transit Networks Congestion Mitigation/Air Quality (CMAQ) Projects Travel Demand Model Mode Split / Mode Choice Method of Reporting VMT and Speed REGIONAL EMISSIONS TEST Sub-area emission budgets Emissions analysis source Emission comparison Years (ozone) Emission comparison Years (CO) Emission comparison Years (PM2.5) Emission Model Development of Emission factors Transportation Conformity Measures Emission Comparison Test by location and Pollutant PUBLIC INVOLVEMENT AND INTERAGENCY CONSULTATION CONCLUSION

4 List of Appendices (All contained in electronic format) Appendix A: Triad Area Federal Register Notices CO SIP 1-Hour Ozone SIP Appendix B: Interagency Consultation Triad TCPCP Appendix C: Lists of Roadway and Transit Projects (within Nonattainment and Maintenance Areas) C1: Greensboro Urban Area MPO 2035 LRTP Projects and Maps C2: Greensboro Urban Area MPO TIP C3: High Point Urban Area MPO 2035 LRTP Projects and Maps C4: High Point Urban Area MPO TIP C5: Winston-Salem Urban Area MPO 2035 LRTP Projects and Maps C6: Winston-Salem Urban Area MPO TIP C7: Burlington-Graham Urban Area MPO 2035 LRTP Projects and Maps C8: Burlington-Graham Urban Area MPO TIP C9: Davidson County STIP C10: Davie County STIP C11: Statewide STIP Appendix D: CMAQ Projects Appendix E: MOBILE 6.2 Emissions Factors Full MOBILE 6.2 Emission Factor Computer Run files can be obtained by request from the NC Division of Air Quality from Janice Godfrey, Environmental Engineer Phone: Appendix F: VMT and Speeds Appendix G: Emissions Analysis Results by County 3

5 Appendix H: Public Participation Policies / Advertising Affidavits Appendix I: Public Comments and Responses (This will be added to the CDR in January 2009) Appendix J: Agency Comments and Responses (This will be added to the CDR in January 2009) Appendix K: MPO TAC Conformity Determination Resolutions (2035 LRTPs, TIP) (This will be added to the CDR in February 2009) Greensboro MPO 2035 LRTP and MTIP High Point MPO 2035 LRTP and MTIP Winston Salem 2035 LRTP and MTIP Burlington-Graham 2035 LRTP and MTIP Appendix L: MPO TAC 2035 LRTP Adoptions (This will be added to the CDR in February 2009) Greensboro MPO 2035 LRTP High Point MPO 2035 LRTP Winston Salem 2035 LRTP Burlington-Graham 2035 LRTP Appendix M: State and Federal Conformity Determinations (This will be added to the CDR in February 2009) Donut Davidson County - NCDOT Donut Davie County NCDOT Triad MPO s Federal Agencies 4

6 List of Acronyms Acronym BGMPO Conformity Analysis Conformity Finding CMS CMAQ DAQ DENR Emissions Budget EIS FHWA FCEAD FTA GUAMPO HPMPO LRTP MAB MPO MTIP MVEB Full Term Burlington-Graham Metropolitan Planning Organization. Demonstration that when the projects planned in the TIP and LRTP are implemented the area will not exceed allowable motor vehicle emissions thresholds (emissions budgets). Statement that the projects contained in the MTIP are essentially consistent with those listed in the LRTP and that no new Conformity Analysis is needed to account for noted differences. Congestion Management System. A program of strategies for monitoring, evaluating, and addressing traffic congestion. Required for Transportation Management Areas. Congestion Mitigation and Air Quality Program. A federal highway fund category for projects that will improve air quality. Division of Air Quality. North Carolina Department of Environment and Natural Resources. See Conformity Analysis. Environmental Impact Statement. Federally required environmental study for projects with potentially significant environmental effects. Federal Highway Administration (USDOT) Forsyth County Environmental Affairs Department. Federal Transit Administration (US Department of Transportation) Greensboro Urban Area Metropolitan Planning Organization. High Point Metropolitan Planning Organization. Long Range Transportation Plan: 25 year planning document identifying long and short term transportation investment needs. Metropolitan Area Boundary. The boundary of the area within the transportation planning jurisdiction of an MPO. Metropolitan Planning Organization. Metropolitan Transportation Improvement Program. Motor Vehicle Emission Budgets. 5

7 NCDOT NEPA NOx PART Prospectus Planning Work Program RPO Section 104(f) PL SIP STIP TCM TDM North Carolina Department of Transportation. National Environmental Policy Act. Federal law that requires consideration of environmental impacts for all major expenditures of federal funds. Oxides of Nitrogen: key precursor to smog. According to NCDAQ, roadway sources produce around 31% of total NC NOx emissions. Piedmont Authority for Regional Transportation. Document outlining responsibilities and procedures for carrying out the cooperative transportation planning process. Defines ongoing work tasks cited in the Planning Work Program. Accounting document for use of planning grant funds; lists approved activities that these funds may reimburse. The PWP thus guides transportation planning activities for the year. Rural Planning Organization. RPOs are partnerships among non-mpo counties, established to provide rural areas a greater voice in state transportation decisions affecting those areas. Funds distributed through the Federal Highway Administration for transportation planning tasks. State Implementation Plan. The modeling analysis and the state and federal regulations demonstrating that the air in an area will meet National Ambient Air Quality Standards. State Transportation Improvement Program Transportation Control Measures. Specific projects or programs enumerated in the SIP that are designed to improve air quality are implemented in a timely fashion. Travel Demand Model. TMA Transportation Management Area: urbanized area over 200,000 in population. PTRM Piedmont Triad Regional Model. US EPA United States Environmental Protection Agency. WSMPO Winston-Salem Metropolitan Planning Organization. 6

8 Conformity Analysis and Determination Report 2035 Long Range Transportation Plans: Burlington-Graham Metropolitan Planning Organization (Guilford County) Greensboro Urban Area Metropolitan Planning Organization (Guilford County) High Point Urban Area Metropolitan Planning Organization (Guilford, Davidson and Forsyth Counties) Winston-Salem Urban Area Metropolitan Planning Organization (Forsyth, Davidson and Davie Counties) Overview Transportation Conformity ("conformity") ensures that Federal funding and approval is distributed to those transportation activities that are consistent with air quality goals. Conformity applies to Long Range Transportation Plans (LRTPs), Transportation Improvement Programs (TIPs), and projects funded or approved by the Federal Highway Administration (FHWA) or the Federal Transit Administration (FTA) in areas that do not meet or previously have not met air quality standards for ozone, carbon monoxide, particulate matter, or nitrogen dioxide. These areas are known as "nonattainment areas" or "maintenance areas," respectively. A conformity determination demonstrates that the total emissions projected for a plan or program are within the emissions limits ("budgets") established by the air quality plan or State Implementation Plan (SIP) for air quality, and that transportation control measures (TCMs) specific projects or programs enumerated in the SIP that are designed to improve air quality are implemented in a timely fashion. Conformity Determination Regional emissions are estimated based on highway and transit usage according to LRTPs and TIPs. The projected emissions for the LRTPs and the TIPs must not exceed the emissions limits (or "budgets") established by the SIP (or less than baseline emissions where no SIP budgets have been approved or found adequate). Where TCMs are included, responsible Metropolitan Planning Organizations (MPOs) and the North Carolina Department of Transportation (NCDOT) are required to demonstrate that TCMs are implemented in a timely fashion to obtain conformity. The Decision Process A formal interagency consultation process involving the Environmental Protection Agency (EPA), FHWA, FTA and State and Local transportation and air quality agencies is required in developing SIPs, TIPs, LRTPs, and in making conformity determinations. MPO policy boards make initial conformity determinations in metropolitan areas, while NCDOT makes this determination in areas outside of MPOs, in consultation with affected Rural Planning Organizations (RPOs). Five organizations are responsible for making the conformity determinations in five distinct parts of the Triad Nonattainment/Maintenance Area: 7

9 a. the Burlington-Graham Urban Area MPO (BGMPO) within its portion of the metropolitan area boundary in Guilford County; b. the Greensboro Urban Area MPO (GUAMPO) within the metropolitan area boundary of Guilford County; c. the High Point Urban Area MPO (HPMPO) within its metropolitan area boundary part in Guilford, Davidson and Forsyth Counties; d. the Winston-Salem Urban Area MPO (WSMPO) within its portion of the metropolitan area boundary in Forsyth, Davidson and Davie Counties e. the NCDOT in the rural (donut) areas that is comprised of those county portions of Davidson and Davie that remain outside of any MPO metropolitan area boundary. Each of these responsible organizations must make a conformity determination for its respective area in order for all of the areas to be designated in conformity. Conformity determinations must also be made at the Federal level by FHWA and FTA. These determinations must be made at least every four years, or with the updating of LRTPs or TIPs, or within one year of the effective date of a non-attainment designation. Conformity analysis is made available to the public as part of the MPO and/or State DOT planning processes. MPOs are required to make LRTPs, TIPs, and conformity determinations available to the public, accept and respond to public comments, and provide adequate notice of relevant public meetings. Project sponsors of specific transportation projects within the LRTPs and TIPs must also include appropriate public involvement during project development. Emissions Budget The SIP places limits on emissions of each pollutant for each source type (mobile, stationary, and area sources). Projected emissions from highway and transit usage must be less than or equal to the emissions limits for on-road mobile vehicles that are established by the SIP (or less than baseline emissions where no SIP budgets have been approved or found adequate). These emissions limits for motor vehicle emissions sources are called "budgets." Budgets are developed as part of the air quality planning process by State air quality/environmental agencies, and approved by EPA. Transportation agencies participate in this process. Transportation Control Measures (TCMs) Areas can include TCMs in their SIPs. TCMs are specific programs designed to reduce emissions from transportation sources by reducing vehicle use or changing traffic flow or congestion conditions. These programs can include: developing high occupancy vehicle (HOV) facilities ordinances to promote non-motor vehicle travel transit improvements signal timing bicycle and pedestrian facilities land use planning 8

10 Executive Summary The purpose of this report is to comply with the provisions of the Clean Air Act Amendments of 1990 and the Safe Accountable Flexible Efficient Transportation Equity Act-Legacy for Users (SAFETEA-LU) of This report demonstrates that the activities resulting from the implementation of the fiscally constrained long-range transportation plans (LRTPs) will not cause or contribute to any new violation of any standard in any area, increase the frequency or severity of any existing violation of any standard in any area, or delay timely attainment of any standard or any required interim emission reductions or other milestones in any area. of the following jurisdictions: The portion of Guilford County within the Burlington-Graham Urban Area Metropolitan Planning Organization (BGMPO) The portions of Guilford County within the Greensboro Urban Area Metropolitan Planning Organization (GUAMPO) The portions of Guilford, Davidson and Forsyth Counties within the High Point Urban Area Metropolitan Planning Organization (HPMPO) The portions of Forsyth, Davidson and Davie Counties within the Winston-Salem Urban Area Metropolitan Planning Organization (WSMPO) The portions of Davidson and Davie Counties outside the MPO boundary that are in the Triad Non-Attainment Area/Maintenance. This conformity determination is based on a regional emissions analysis that uses the transportation network approved by the above-named Metropolitan Planning Organizations (MPOs) for the 2035 LRTPs, VMT and Speed input data developed by NCDOT, and emissions factors developed by the North Carolina Division of Air Quality (NCDAQ). Based on this analysis, the 2035 LRTPs for the Piedmont Triad Region (BGMPO, GUAMPO, HPMPO, WSMPO and the relevant county portions of Davidson and Davie) are consistent with the intent of conformity requirement. The conformity analysis for the relevant portion of the Piedmont Triad Rural Planning Organization (RPO) during the TIP years is specifically addressed by the North Carolina Department of Transportation (NCDOT). The NCDOT s analysis also shows the TIPs conform to the purpose of the North Carolina SIP (or less than baseline emissions where no SIP budgets have been approved or found adequate). The USEPA designated the counties of Guilford, Davidson, Forsyth and Davie for the one hour ozone (O 3 ) standard. The 1990 Clean Air Act Amendments (CAAA) designated these areas as moderate non-attainment area for the one hour O 3 standard. However, due to improved monitoring data, this area was redesignated as maintenance for the one hour O 3 standard on November 8, On April 2, 2008, the USEPA revoked the one-hour standard for the Triad Area counties of Guilford, Davidson, Forsyth and Davie under rulemaking effective on April 15, As of April 15, 2009, the Triad Area will no longer have to demonstrate conformity for the one-hour ozone (O3) standard. The USEPA designated Forsyth County for carbon monoxide (CO) as defined by the EPA. The 1990 Clean Air Act Amendments (CAAA) designated these areas as moderate non-attainment 9

11 area for CO. However, due to improved monitoring data, this area was redesignated as maintenance for CO on November 7, The USEPA designated Davidson and Guilford Counties, in their entirety, as a non-attainment area for the PM 2.5 Standard with an effective date of April 5, The Triad Area LRTPs have the following horizon years: 2015, 2025 and Each analysis year includes anticipated population, employment data, and roadway projects that are expected open. The LRTPs are fiscally constrained meaning that funding sources for roadway projects are identified. NCDAQ prepared base and future emission rates for the vehicle fleet using Mobile 6.2. These rates were applied to VMT from the Piedmont Triad Regional Model (PTRM) and the rural spreadsheet. There are State Implementation Plan (SIP) motor vehicle emission budgets (MVEB) for the 1-hour ozone and CO standards. MVEBs are currently proposed for the PM 2.5 standard. Table 1 summarizes the conformity requirements of 40 CFR Part 51 and 93 and gives the status of the LRTPs in relation to each of these requirements. Table 2 contains results from the regional emissions analysis for the Triad Non-attainment/Maintenance Areas (Davidson, Guilford, Forsyth and Davie Counties). In every horizon year for every pollutant in each geographic area, the emissions expected from the implementation of the LRTP and TIP are less than the emissions budgets established in the SIP (or less than baseline emissions where no SIP budgets have been approved or found adequate). Table 4 contains a cross-reference index for the report. Table 1. Status of Conformity Requirements Criteria ( indicates the criterion is met) Burlington -Graham MPO Greensboro MPO Forsyth MPO High Point MPO Rural County Portion of Davidson and Davie Less Than Emissions Budget(s) or Baseline TCM Implementation N/A N/A N/A N/A N/A Interagency Consultation Latest Emissions ** Model Latest Planning Assumptions Fiscal Constraint ** Rural spreadsheet was used 10

12 Table 2. Emissions Comparison Summary Forsyth County Emissions Comparison Summary Analysis Year Forsyth County Emissions Comparison 1 NOX VOC LRTP Emissions SIP Budget Amount LRTP Emissions SIP Budget Amount Forsyth County Emissions Comparison 1 CO Analysis Year LRTP Emissions SIP Budget Amount Guilford County Emissions Comparison Summary Analysis Year Guilford County Emissions Comparison 1 NOX VOC LRTP Emissions SIP Budget Amount LRTP Emissions SIP Budget Amount

13 Guilford County Interim Test (Less than Baseline) Emissions Comparison (KG/Year) PM2.5 Analysis Year LRTP Emissions (KG/Year) 2002 Baseline Emission (KG/Year) , , , , , , , , ,008 Analysis Year Guilford County NOx (for PM 2.5) LRTP Emissions (KG/Year) 2002 Baseline Emission (KG/Year) ,142, ,812,825 14,142, ,436,572 14,142, ,247,062 14,142, ,157,763 14,142,913 Davidson County Emissions Comparison Summary Analysis Year Davidson County Emissions Comparison 1 NOX VOC LRTP Emissions SIP Budget Amount LRTP Emissions SIP Budget Amount Davidson County Interim Test (Less than Baseline) Emissions Comparison (KG/Year) PM2.5 Analysis Year LRTP Emissions (KG/Year) 2002 Baseline Emission (KG/Year) , ,233 90, ,225 90, ,970 90, ,058 90,656 12

14 Analysis Year Davidson County NOx (for PM 2.5) LRTP Emissions (KG/Year) 2002 Baseline Emission (KG/Year) ,638, ,915,785 5,638, ,651,675 5,638, ,256 5,638, ,232 5,638,248 Davie County Emissions Comparison Analysis Year Davie County Emissions Comparison 1 NOX VOC LRTP Emissions SIP Budget Amount LRTP Emissions SIP Budget Amount

15 Table 4. Cross-reference Index Conformity Determination Report for the Long-Range Transportation Plan in the Triad Urban Area Non- Attainment/Maintenance Area Conformity Requirement Federal Register Formal findings of conformity. Table of Contents. The purpose of this report is to comply with the requirements of the CAAA, TEA- 21, and 40 CFR 51 and 93. The former and current classification of the air shed and the pollutants for which the air shed was classified as non-attainment. Appendix A to be added iii p. 4 p. 10 The date the region was designated non-attainment under the PM 2.5 standard. p. 16 The emissions expected from implementation of the long-range plan are equal to, or less than, the base year emissions generated p. 16 The adopted long-range plan is fiscally constrained ( ). p. 17 The latest planning assumptions were used in the conformity analysis ( ). p. 18 Appendix B The latest emissions model was used in the conformity analysis ( ). p. 23 The list of federally funded T.C.M. activities included. ( ). NA Conformity determined according to and the adopted public involvement procedures. Dates of the Technical Coordinating Committee reviews of the conformity determination and the recommendation. SIP emissions budget test or baseline comparison demonstrates conformity of the adopted long-range transportation plan. Listing of projects in each analysis year (highway). VMT & Summary Analysis of rural area projects. Off-model analysis performed. Significant comments of reviewing agencies addressed by the MPO, or a statement that no significant comments were received. Emissions Calculations. Mobile input files. p. 33 to be added p. 29 Appendix C p. 29, Appendix F Appendix G Appendix G Appendix B Appendix E Appendix G 14

16 Conformity Analysis and Determination Report 2035 Long Range Transportation Plans: Final Burlington-Graham Metropolitan Planning Organization (Guilford County) Greensboro Urban Area Metropolitan Planning Organization (Guilford County) High Point Urban Area Metropolitan Planning Organization (Guilford, Davidson and Forsyth Counties) Winston-Salem Urban Area Metropolitan Planning Organization (Forsyth, Davidson and Davie Counties) Projects from the FY Transportation Improvement Program: The portions of Davidson and Davie County that are within the Triad Non- Attainment/Maintenance Area but outside the Metropolitan Planning Organization Areas 1 Introduction The Clean Air Act requires the United States Environmental Protection Agency (USEPA) to set limits on how much of a particular pollutant can be in the air anywhere in the United States. National Ambient Air Quality Standards (NAAQS) are the pollutant limits set by the USEPA; they define the allowable concentration of pollution in the air for six different pollutants Carbon Monoxide, Lead, Nitrogen Dioxide, Particulate Matter, Ozone, and Sulfur Dioxide. The Clean Air Act specifies how areas within the country are designated as either attainment or non-attainment of an air quality standard, and provides USEPA the authority to define the boundaries of non-attainment areas. For areas designated as non-attainment for one or more NAAQS, the Clean Air Act defines a specific timetable to attain the standard and requires that non-attainment areas demonstrate reasonable and steady progress in reducing air pollution emissions until such time that an area can demonstrate attainment. Each state must develop and submit a State Implementation Plan (SIP) that addresses each pollutant for which it fails to meet the NAAQS. Individual State air quality agencies are responsible for defining the overall regional plan to reduce air pollution emissions to levels that will enable attainment and maintenance of the NAAQS. This strategy is articulated through the SIP. In North Carolina, the agency responsible for SIP development is the North Carolina Division of Air Quality (NCDAQ). The delineation and implementation of strategies to control emissions from on-road mobile sources is a significant element of the state plan to improve air quality, thereby creating a direct link between transportation and air quality planning activities within a non-attainment area. The process of ensuring that a region s transportation planning activities contribute to attainment of the NAAQS, or conform to the purposes of the SIP, is referred to as transportation conformity. In order to receive federal transportation funds within the nonattainment area, the area must demonstrate through a federally mandated conformity process that the transportation investments, strategies and programs, taken as a whole, contribute to the air quality goals defined in the state air quality plan. 15

17 In order to ensure the conformity requirements are met, Section 176 (c) of the Clean Air Act authorizes the USEPA Administrator to promulgate criteria and procedures for demonstrating and assuring conformity in the case of transportation plans, programs, and projects. This is accomplished through the Transportation Conformity Rule; developed by the USEPA to outline all federal requirements associated with transportation conformity. The Transportation Conformity Rule in conjunction with the Metropolitan Planning Regulations direct transportation plans and program development as well as the conformity process. The purpose of this report is to comply with the provisions of the Clean Air Act Amendments of 1990 and the Safe Accountable Flexible Efficient Transportation Equity Act-Legacy for Users (SAFETEA-LU) This report demonstrates that the activities resulting from the implementation of the fiscally constrained LRTPs and the TIPs will not cause or contribute to any new violation of any standard in any area, increase the frequency or severity of any existing violation of any standard in any area, or delay timely attainment of any standard or any required interim emission reductions or other milestones in any area. The following jurisdictions apply: The portion of Guilford County within the Burlington-Graham Urban Area Metropolitan Planning Organization (BGMPO) The portion of Guilford County within the Greensboro Urban Area Metropolitan Planning Organization (GUAMPO) The portions of Guilford, Davidson and Forsyth Counties within the High Point Urban Area Metropolitan Planning Organization (HPMPO) The portions of Forsyth, Davidson and Davie Counties within the Winston-Salem Urban Area Metropolitan Planning Organization (WSMPO) The county portions of Davidson and Davie outside the MPO boundary that are in the Triad Non-Attainment/Maintenance Areas. This conformity determination is based on a regional emissions analysis that uses the transportation network approved by the above-named Metropolitan Planning Organizations (MPOs) for the 2035 LRTPs, VMT and Speed input data developed by NCDOT, and emissions factors developed by the Forsyth County Environmental Affairs Department (FCEAD) in cooperation with the North Carolina Division of Air Quality (NCDAQ). The Triad nonattainment areas for Guilford, Davidson Forsyth and Davie Counties for 1-hour ozone, CO and PM 2.5 are shown as a map on Figure 1. All Federally funded projects in areas designated by the United States Environmental Protection Agency (USEPA) as air quality non-attainment or maintenance areas must come from a conforming long-range transportation plan and transportation improvement program (TIP). Triad MPO non-attainment and maintenance areas are required by 23 CFR 134 and 40 CFR 51 and 93 to make a conformity determination on any adopted or amended fiscally constrained long-range transportation plan and related TIP. In addition, the United States Department of Transportation (USDOT), specifically, the Federal Highway Administration (FHWA) and the Federal Transit Administration (FTA) must make a conformity determination on four MPO Plans in the Triad region and the related TIPs for the non-attainment and maintenance areas. 16

18 Figure 1A. Triad Area PM 2.5 Non-attainment Areas 17

19 Figure 1B. State of North Carolina Ozone Non-attainment Areas 18

20 Figure 1C. State of North Carolina CO Non-attainment Areas 19

21 In order to assist the Triad Area in making a conformity determination on the adopted 2035 fiscally constrained LRTPs, the following agencies shared leading roles composing substantial portions of this document: Table 5. Agency Counties BGMPO Guilford (part) Greensboro MPO Guilford (part) High Point MPO Guilford (part), Davidson (part) and Forsyth (part) Winston-Salem MPO Forsyth, Davidson (part) and Davie (part) NCDOT Forsyth, Davidson, Davie and Guilford This analysis is consistent with the set of amendments to 40 CFR Part 93, published in the January 24, 2008 Federal Register, Transportation Conformity Rule Amendments to Implement Provisions Contained in the 2005 Safe, Accountable, Flexible, Efficient, Transportation Equity Act: A legacy for Users (SAFETEA-LU). Based on the regional emissions budget test and interim tests documented in this report, the following LRTPs conforms to the purpose of the North Carolina SIP (or less than baseline emissions where no SIP budgets have been approved or found adequate): Greensboro Urban Area MPO 2035 LRTP & TIP Projects High Point Urban Area MPO 2035 LRTP & TIP Projects Winston-Salem Urban Area MPO 2035 LRTP & TIP Projects Burlington-Graham Urban Area MPO 2035 LRTP & TIP Projects Rural County Portions of Davidson and Davie TIP Projects outside of the MPO boundaries This report documents the regional emissions budget test, the interim emissions test, interagency consultation process, public involvement process, and analysis methodology used to demonstrate transportation conformity for each MPO and the rural portion of each county outside the MPOs. 40 CFR Part 93 requires that a conforming transportation plan satisfy five conditions: The transportation plan must be consistent with the motor vehicle emissions budget(s) in an area where the applicable implementation plan or implementation plan submission contains a budget (40 CFR Part ). The transportation plan, TIP, or FHWA/FTA project not from a conforming plan must provide for the timely implementation of TCMs from the applicable implementation plan (40 CFR Part b). The MPO must make the conformity determination according to the consultation procedures of 40 CFR Part and the implementation plan revision required by 40 CFR Part (40 CFR Part 416). The conformity determination must be based on the latest emissions estimation model available (40 CFR Part ). The conformity determination must be based on the latest planning assumptions (40 CFR Part ). The transportation Plan, TIP, or FHWA/FTA project must meet the interim emissions tests where applicable (40 CFR Part ). This report shows that the MPOs 2035 LRTPs and the projects out of the STIPs in rural areas outside of the MPO boundaries meets each condition. Each condition is discussed in the following sections of this report. 20

22 2 Air Quality Planning The USEPA designated the counties of Guilford, Davidson, Forsyth and Davie for the one hour ozone (O 3 ) standard. The 1990 Clean Air Act Amendments (CAAA) designated these areas as moderate non-attainment area for the one hour O 3 standard. However, due to improved monitoring data, this area was redesignated as maintenance for the one hour O 3 standard on November 8, On April 2, 2008, the USEPA revoked the one-hour standard for the Triad Area counties of Guilford, Davidson, Forsyth and Davie under rulemaking effective on April 15, As of April 15, 2009, the Triad Area will no longer have to demonstrate conformity for the one-hour ozone (O3) standard. The USEPA designated Forsyth County for carbon monoxide (CO) as defined by the EPA. The 1990 Clean Air Act Amendments (CAAA) designated these areas as moderate non-attainment area for CO. However, due to improved monitoring data, this area was redesignated as maintenance for CO on November 7, The USEPA designated Davidson and Guilford Counties, in their entirety, as a non-attainment area for the PM 2.5 Standard with an effective date of April 5, The Federal Register notices containing the SIP MVEBs for each designated pollutant for the Triad Area is provided in Appendix A. 2.1 Emissions Budget and Baseline Emissions NCDOT performed the less than the base year (2002) analysis as the interim emissions tests for direct PM2.5 and NOx. NCDAQ is currently working on the SIP for the Triad PM2.5 nonattainment area so it is not likely that the MVEBs will be found adequate or approved by the time this transportation conformity determination is completed. Therefore, the Triad PM2.5 nonattainment area (Davidson and Guilford Counties), future long range transportation plan and TIP emissions can not be compared to a budget, but are instead compared to emissions estimated from PTRM and Rural spreadsheet models for the 2002 baseline year. The following requirements have been addressed as part of this conformity determination. For the 1-hour ozone and CO standard there are approved SIP MVEBs and comparisons will be made to the MVEBs to demonstrate conformity. Section 4 of this report provides the regional emissions analysis using the interim emissions tests and comparisons to the MVEBs where applicable. 21

23 Table 6: Motor Vehicle Emission Budgets Forsyth County is maintenance for the Carbon Monoxide (CO) standard. A MVEB was established for 2015 and emission limits based on the MVEB is indicated below: CO: Current CO SIP (tons/day) Area Comparison Year ** 2035** Forsyth NA NA NA **The MVEB for 2015 will be used for the 2025 and 2035 comparison since 2015 is the last year that a MVEB is provided for VOC and NOx 1-Hour Ozone (Safety Margin SIP revision): VOC: Proposed 1-hour Ozone SIP (tons/day) Area Comparison Year ** 2035** Davidson Davie* Forsyth Guilford Vol. 73, No. 68, effective June 9, 2008 NOx: Proposed 1-hour Ozone SIP (tons/day) Comparison Area Year ** 2035** Davidson Davie* Forsyth Guilford Vol. 71, No. 57, effective May 23, 2006 *Davie County is a partial county **The MVEB for 2015 will be used for the 2025 and 2035 comparison since 2015 is the last year that a MVEB is provided for VOC and NOx 3 Long Range Transportation Plans Federal law 40 CFR part (b)(3) requires a conformity determination on LRTPs no less frequently than every four years. As required in 40 CFR , the horizon years for the LRTPs are no more than ten years apart. The BGMPO includes a small portion Guilford County. The GUAMPO includes the majority portion of Guilford County. The HPMPO includes portions of Guilford, Davidson, and Forsyth Counties. WSMPO includes Forsyth County and portions of Davidson and Davie Counties. The remaining portions of the non-attainment area are rural areas of Davidson and Davie Counties outside of the MPO boundaries. 22

24 3.1 Consultation The 2035 LRTP is consistent with consultation requirements discussed in 40 CFR Consultation on the development of this conformity determination was accomplished through interagency consultation meetings held on October 30, 2007, November 29, 2007, January 4, 2008, February 8, 2008, March 14, 2008, April 18, 2008, May 19, 2008, May 22, 2008, June 12, 2008, June 19, 2008, June 27, 2008, July 3, 2008, August 26, 2008, and November 10, A summary of the topics discussed and a list of the attendees at each of these meetings is included in Appendix B. 3.2 Financial Constraint Assumptions The LRTPs are fiscally constrained as discussed in 40 CFR The Greensboro Urban Area MPO, the High Point Urban Area MPO, the Winston-Salem Urban Area MPO and the Burlington- Graham LRTPs are fiscally constrained to the year All projects included in the TIPs are fiscally constrained, and funding sources have been identified for construction and operation. The estimates of available funds are based on historic funding availability and include federal, state, private, and local funding sources. Additional detail on fiscal constraint is included in each MPO LRTP. It is assumed that the projects listed for each horizon year will be completed and providing service by the end of the indicated calendar year (December 31). These transportation networks are described in the respective 2035 LRTPs. They are also described in greater detail in Appendix C. 3.3 Latest Planning Assumptions The 2035 LRTPs were developed with the latest planning assumptions as discussed in 40 CFR The Piedmont Travel Demand Model (PTRM) was developed by NCDOT, Triad MPOs, and PART for the urbanized portion of the Triad non-attainment area. The MPOs provided housing, employment, and population projections, and a set of highway and transit projects consistent across jurisdictional boundaries was developed through regional MPO coordination. Additional detail on these planning assumptions is provided below. Land use and demographic data were collected by regional planning agencies and staff members of BGMPO, GUAMPO, HPMPO and WSMPO. A regional methodology was agreed upon that included updating residential and employment data to the end of 2002, and preparing growth forecasts to Residential data included population, dwelling units, households, median income and universityrelated group quarters population (dormitories, fraternities and sororities). Residential data was based on Census 2000 data from Summary File 1, except that median income data was based on the Census Transportation Planning Package part 1. Forecasts were prepared by local planning department staff with guidance from staff at the four MPOs. A regional methodology was applied to maintain consistency between residential and employment forecasts and adopted land use plans. Data and forecasts were submitted for public 23

25 review by each MPO, and adopted for use in developing travel demand and air quality forecasts by each MPOs Transportation Advisory Committee. Additional detail of arriving at these planning assumptions can be found in Appendix B for the Triad Transportation Conformity Consensus Plan. The Piedmont Triad Regional Model (PTRM) uses the basic four-step process (trip generation, trip distribution, mode choice and assignment). All four steps of the process are discussed in greater detail in the sections below. The PTRM TransCAD model was developed by the PTRM Model Team, and adopted by the Executive Committee, and is housed at PART. The PTRM TransCAD model covers the contiguous boundaries of Guilford and Forsyth Counties (including the portions within the BG MPO) and a portion of Davidson County (including the portion within the HPMPO, and WSMPO) Outside of the modeled area, NCDOT utilizes a spreadsheet that incorporates the vehicle-miles traveled (VMT) universe file and historical trends to project the VMT in future years at the county level. The spreadsheet calculates speed based on a model originally developed by the Texas Transportation Institute (TTI) but modified by NCDOT. Speeds generated by the spreadsheet are incorporated into the MOBILE6.2 emissions program. Then, emission factors developed by MOBILE6.2 are imported into the spreadsheet and multiplied by forecasted VMT to generate emissions. The rural spreadsheet model is used for the county rural areas of Davidson and Davie and is factored based on population percentage for those portions of non-attainment counties not covered by the PTRM TransCAD model. This methodology has been used to demonstrate conformity in other areas and has received approval from interagency partners. There are no court orders or special agreements that apply to conformity (40 CFR ). 3.4 Future Year Roadway Projects Roadway improvements used for conformity modeling were developed in the 2035 LRTP process in each MPO. Outside of the MPO boundaries, TIP projects from the TIP served as the future year roadway projects. For the 2035 LRTPs, lists of needed projects were developed based on modeled congestion and identified local needs. Improvements were coded into the TDM and analyzed. Intermediate analyses for the years 2015, and 2025 were performed to assist in prioritizing the 2035 roadway needs. The final 2009, 2015, 2025 and 2035 networks are fiscally constrained. Projects were added from MPO priority lists until estimated project costs equaled the expected funding available. The base network (2002) and the four future networks (2009, 2015, 2025, and 2035) used for the conformity determination are the same as the networks used for the 2035 LRTPs. Throughout the process to develop the roadway networks, the MPOs and NCDOT identified any initial inconsistencies in project timing and characteristics (e.g. cross-section) for those projects crossing jurisdictional boundaries and reached consensus on consistent solutions. Figure 2. Regional Significance The following criteria is used to identify major existing and future regional roadway systems that may produce significant impacts to air quality emissions with respect to the Triad region. 24

26 Regional Significance Criteria 1. The facility serves regional transportation needs (i.e. facilities that provide access to and from the region or that provide access to major destinations in the region); 2. The facility is functionally classified higher than a minor arterial (minor arterials may be regionally significant if their main purpose is to provide access to major facilities in the region); 3. The facility is a fixed guideway transit facility; and 4. The facility is included in the travel model for the region (In many cases collector streets are modeled that are not regionally significant). To be regionally significant a facility should meet one or more of the criteria in this checklist. 40 CFR Part Appendix C includes lists of the future year roadway projects in the Triad area as indicated below, including indications of which projects are regionally significant and which projects are exempt. Table 7. Roadway Project List Area Appendix C Greensboro Urban Area MPO 2035 LRTP (Appendix C1) TIP (Appendix C2) High Point Urban Area MPO 2035 LRTP (Appendix C3) TIP (Appendix C4) Winston-Salem Urban Area MPO 2035 LRTP (Appendix C5) TIP (Appendix C6) Burlington-Graham MPO 2035 LRTP (Appendix C7) TIP (Appendix C8) NCDOT (Rural County portion of Davidson and Davie) TIP (Appendix C9 and C10) The exempt projects listed in Appendix C, both highway and transit, will serve as the LRTPs/TIPs for the region in the event of a conformity lapse. A conformity lapse is when an area develops a LRTP that does not pass the conformity test. The TAC must adopt a LRTP of exempt projects (40 CFR , 127 & 128) that will serve as the LRTP/TIP for the area in the event of conformity lapse. This will allow exempt projects to receive federal funding. A planning lapse is when an area has missed their required LRTP update date. During a planning lapse new Federal aid funds are stopped for all projects INCLUDING exempt projects (40 CFR , 127 & 128). 3.5 Transit Networks As with the roadway projects, each MPO developed transit projects for its LRTP. The base year network was modeled from existing routes and fares for the transit systems in Future year networks were based on fiscally-constrained projected new or expanded services from regional transit plans, local bus system short range plans, corridor transit plans and other projected bus 25

27 service expansion estimates, where available. As with the roadway networks, the MPOs and NCDOT identified and rectified any initial inconsistencies in project characteristics or implementation years where transit projects crossed jurisdictional boundaries. Table 8. Area Transit Project List Appendix C Greensboro Urban Area MPO 2035 LRTP (Appendix C1) High Point Urban Area MPO 2035 LRTP (Appendix C3) Winston-Salem Urban Area MPO 2035 LRTP (Appendix C5) Burlington-Graham MPO 2035 LRTP (Appendix C7) NCDOT (Rural County portion of Davidson and Davie) TIP (Appendix C9 and C10) 3.6 Congestion Mitigation/Air Quality (CMAQ) Projects The NC Department of Transportation has established an allocation and review process for CMAQ projects. Each MPO and RPO in a non-attainment or maintenance area receives an allocation of CMAQ funds based on population and air quality status. In addition, a statewide pool of CMAQ funds will be allocated to projects serving more than one non-attainment area on a competitive basis. MPO and RPO project priorities and project applications for statewide funding. This conformity report includes a listing of funded CMAQ projects in the Triad Area in Appendix D, for those projects within the non-attainment/maintenance areas. 3.7 Travel Demand Model: Piedmont Triad Regional Model (PTRM) and the NCDOT Rural Spreadsheet. The PTRM is housed at PART and the rural spreadsheet is housed at NCDOT. The PTRM completely covers the metropolitan area boundaries (MABs) for the WSMPO (Forsyth, Davidson and Davie), the HPMPO (Davidson, Guilford and Forsyth), the GUAMPO (Guilford) and the BGMPO (Guilford). Guilford and Forsyth counties are completely within the Piedmont Triad Regional Model (PTRM) boundary. Davidson and Davie counties are partially covered by the PTRM and the remainder of the county will be covered using the NCDOT rural spreadsheet. NCDOT utilizes a spreadsheet that incorporates the VMT universe file and historical trends to project the VMT to the horizon years at the county level VMT data is expressed as Daily Vehicle Miles of Travel (DVMT). This data is based upon the Annual Average Daily Traffic (AADT) in the universe file. The annual Highway Performance Monitoring System (HPMS) VMT reported to the Federal Highway Administration (FHWA) is derived from a subset of the universe file. North Carolina records AADT data for all roads in all functional classifications. However, only 73.8% of the local functionally classified road mileage was 26

28 covered by actual counts. For links without counts, an Average Daily Traffic (ADT) count of 400 vehicles per day was assumed. The projection of VMT was based on a trend line using an ordinary least squares linear regression extrapolation of a 10-year period for Davie and Davidson Counties. The total VMT, including rural and urban road types, was used to perform statistical analysis. This approach will compensate for the reclassification of VMT from year to year due to the expansion of urbanized boundaries or other reasons. Therefore, a regression analysis was performed to determine the correlation of data and predicted VMT values for the specific years of interest. Finally, 2006 VMT by functional classes (using the ratio of each functional class's VMT to the total VMT) was used to disaggregate projected VMTs. Results were evaluated for reasonable growth and consistency. This VMT projection methodology was based on the EPA document Section 187, VMT Forecasting and Tracking Guidance, January The spreadsheet calculates speed based on a model originally developed by the Texas Transportation Institute (TTI) but modified by NCDOT. Speeds generated by the spreadsheet are incorporated into the MOBILE 6.2 emissions program. Then, emission factors developed by MOBILE 6.2 are imported into the spreadsheet and multiplied by forecasted VMT to generate emissions. The rural spreadsheet model will be used for parts of Davidson and Davie Counties and will be factored based on population percentages for those portions of non-attainment counties not covered by the PTRM. This methodology has been used to demonstrate conformity in other areas and received approval from the interagency partners. 3.8 Mode Split / Mode Choice: Piedmont Triad Regional Model (PTRM) The PTRM estimates the probability of selecting the entire range of travel modes (excluding freight) for each potential origin and destination in the region, as defined by the regional network and zone system. The mode split model uses a logit formulation to estimate the probability of choosing a particular mode. For the PTRM a total of 28 model alternatives (travel modes) are considered. While not all of these modes are allowed for each purpose, and some await data for calibration, the model structure is designed to accommodate a full range of potential alternatives. The primary or top level alternatives are auto, non-motorized, transit and school bus. Within each of the primary alternatives considered there are separate nest created for alternative travel patterns; thus creating a total of 28 alternatives. The PTRM includes the following trip purposes: home-based work, home-based school, homebased shopping, home-based other, Non-home-based work, non-home-based other, home-based college/university, and airport traveler trips. 3.9 Method of Reporting VMT and Speed The PTRM was developed in 2007 with 2004 ground counts and projected to 2008 model counts using an equilibrium loading method. This method assigns vehicle trips based on equalizing the capacity on the network links. After the vehicle trips are assigned, the PTRM must be separated by designated non-attainment region to be analyzed independently. For each designated non-attainment area, the PTRM has the capability to provide daily VMT and Speed output for each fiscally constrained analysis year network corresponding to programmed 27